I’m sorry but I don’t see how this is helping. To say that we strongly oppose the regulation but to propose any type of wording is contradictory. Also, the regulation still reads vague so how can we be sure that this wording will be considered ok or if the insurance department isn’t going to change the rules of the game again? My point is that this regulation is not valid in the first place so why are they negotiating?
Sometimes it’s easier to jump through the hoop to start with so you’ve a firm place to stand while you work on your dispute.
This is especially true since it shows to the general public who are not familiar with insurance matters that we are following government guidelines while the details are being hammered out & that we’re not trying to hide anything (especially after the comments the deputy commissioner recently made).
Besides, I’m sure that the PIANY got the approval for this form in writing from the NYDOI. That means if at some point down the line the regulators say that it’s not compliant, they can wave that piece of paper and tell them to back off.
The problem is that opinion is only good until someone issues a new one saying something else. Don’t forget, the current NYS government is on its way out in January of 2011 (when this abominiation of a law takes effect) and whoever Cuomo appoints Superintendent is likely to be much less forgiving on agents and brokers given Cuomo’s background.
PIANY never misses an opportunity to miss an opportunity. Maybe they’ll reimburse me for all of the paper and toner I’ll be going through to get their statement out to all my clients.
I’m sorry but I don’t see how this is helping. To say that we strongly oppose the regulation but to propose any type of wording is contradictory. Also, the regulation still reads vague so how can we be sure that this wording will be considered ok or if the insurance department isn’t going to change the rules of the game again? My point is that this regulation is not valid in the first place so why are they negotiating?
Sometimes it’s easier to jump through the hoop to start with so you’ve a firm place to stand while you work on your dispute.
This is especially true since it shows to the general public who are not familiar with insurance matters that we are following government guidelines while the details are being hammered out & that we’re not trying to hide anything (especially after the comments the deputy commissioner recently made).
Besides, I’m sure that the PIANY got the approval for this form in writing from the NYDOI. That means if at some point down the line the regulators say that it’s not compliant, they can wave that piece of paper and tell them to back off.
Caffiend- yes, they did get a written opinion from the department- it’s on their website.
http://www.pia.org/COMM/abcd/resources-primary-disclosure-nysid.pdf
The problem is that opinion is only good until someone issues a new one saying something else. Don’t forget, the current NYS government is on its way out in January of 2011 (when this abominiation of a law takes effect) and whoever Cuomo appoints Superintendent is likely to be much less forgiving on agents and brokers given Cuomo’s background.
PIANY never misses an opportunity to miss an opportunity. Maybe they’ll reimburse me for all of the paper and toner I’ll be going through to get their statement out to all my clients.